Understanding Standard 3.2.2A and the New Food Safety Management Tools for Australian Food Businesses

Standard 3.2.2A of the Australia New Zealand Food Standards Code is the instrument that decides whether your business needs a Food Safety Supervisor, trained food handlers, and documented evidence of both. It commenced on 8 December 2023 and applies to category one and category two food businesses.

This page sets out what the standard actually requires, how to work out which category you are in, and — the part that catches most businesses — how the same national standard produces materially different obligations in different states.

The three food safety management tools

So a category one business complies with all three clauses and a category two business with the first two. One clause is the entire difference in obligation between the categories — which is why getting your category right matters more than anything else on this page.

The five-year rule is also worth reading precisely. It is not that the certificate "expires" in the way a licence does. The requirement sits in the definitions clause 3.2.2A—2, and it is that the certificate the business relies on was issued within the last five years. A ten-year-old Statement of Attainment is still a valid record of competency; it just no longer satisfies Standard 3.2.2A.

The layer underneath: clause 3, which has applied since 2000

Before the three tools, there is a duty that Standard 3.2.2A did not create and did not replace. Clause 3 of Standard 3.2.2 has applied to every Australian food business since 2000: the business must ensure that persons undertaking or supervising food handling operations have skills in food safety and food hygiene matters, and knowledge of them, commensurate with their work activities.

Clause 3 is outcome-based. It specifies no course, no certificate, no unit code and no refresher period — only that the competence be present. Its one carve-out is narrow, and it is not the same carve-out as 3.2.2A's: clause 3 does not apply in relation to persons undertaking food handling operations for fundraising events at which the only food sold is food that is not potentially hazardous, or is to be consumed immediately after thorough cooking.

Two consequences that answer the most common misreading of this whole area:

• A business outside categories one and two is not outside food safety training law. It still answers to clause 3. "We are not category one or two" resolves the prescriptive tools, not the underlying duty. In Victoria, that is every Class 3 and Class 4 premises.
• A category one business answers to both. Standard 3.2.2A added a prescriptive layer on top of clause 3 for categories one and two. At an inspection there are two questions, not one: are the tools in place, and is the competence actually there.

Which category are you? The test is what you do, not what you are called

Standard 3.2.2A categorises by activity, not by premises type or by who you serve. The deciding question is whether you process unpackaged potentially hazardous food into food that is both potentially hazardous and ready to eat.

Category one

A category one business is a caterer or food service operation that processes unpackaged potentially hazardous food into food that is both potentially hazardous and ready to eat. That includes:

• Restaurants, cafes and pubs
• Fast food outlets and takeaways
• Bakeries
• Hospitals and aged care facilities
• Childcare centres, school canteens and family day care services
• Mobile food vendors and market stalls
• Service stations, supermarkets and delis that make and serve food — sandwiches, pizza, pasta, salads, meat dishes, cooked chickens

Most of hospitality is category one. If you have a kitchen and you cook, you are almost certainly category one, and all three tools apply to you including the records.

Category two

A category two business offers for retail sale food that is potentially hazardous and ready to eat, where that food was received unpackaged (or unpackaged after receipt) and was not made or processed by the business — with slicing, weighing, repacking, reheating and hot-holding expressly not counting as processing. That includes:

• Delicatessens
• Seafood retailers and butchers
• Some supermarkets, service stations and delis
• Some market stalls and convenience stores handling but not processing unpackaged potentially hazardous food

Category two businesses need the training and the supervisor. They do not carry the substantiation tool.

Who is exempt

Standard 3.2.2A does not apply to food handling at fundraising events that raise funds solely for community or charitable causes rather than personal financial gain, and it does not apply to businesses that do not handle unpackaged, potentially hazardous, ready-to-eat food at all.

The fundraising exemption sits at clause 3(2). Note that it does not travel intact into every state: in Queensland a non-profit holding a food business licence still needs an FSS, because Queensland's trigger is the licence rather than the category. And it does not switch off clause 3 of Standard 3.2.2 except on that clause's own narrower terms.

Tool one in detail: food handler training

The business must ensure each food handler who engages in a prescribed activity has completed training before engaging in it. A prescribed activity means the handling by the business of any unpackaged potentially hazardous food that is either used in the preparation of ready-to-eat food to be served to a consumer, or is ready-to-eat food intended for retail sale by that business. That definition is the trigger point for all three tools, not just for training.

The training must cover four things:

• Safe handling of food
• Food contamination
• Cleaning and sanitising of food premises and equipment
• Personal hygiene

Alternatively, the handler may simply possess skills and knowledge commensurate with the specific prescribed activity.

Three features of this tool surprise people, and all three save money:

No refresher period is mandated. Standard 3.2.2A sets no expiry on food handler training. The obligation is that handlers' skills and knowledge remain adequate and current — a continuing duty on the business, not a fixed retraining clock. This is the opposite of the FSS rule.

No national VET accreditation is required. Food handler training does not have to be a nationally recognised unit, and it need not have a named unit code. Free, non-accredited courses satisfy the standard. An accredited unit such as SITXFSA005 also satisfies it, and produces a portable Statement of Attainment on the handler's national transcript — but the law does not compel it. Only the food safety supervisor needs a certificate from a registered training organisation or a recognised organisation.

Record keeping is optional. The standard does not require the business to keep records of food handler training, though many choose to. Prior learning counts too, and the recognised routes are wider than most operators assume: competency-based training, in-house education, a food safety induction completed at another food business, or relevant previous industry experience in the food industry.

Tool two in detail: the Food Safety Supervisor

The business must appoint an FSS before engaging in a prescribed activity, and ensure they remain reasonably available to advise and supervise food handlers.

An FSS must:

• Hold an FSS certificate issued within the immediately preceding five years
• Have the authority and ability to manage and give direction on safe food handling
• Be reasonably available — working on site, or easily contactable, for example by phone, to give guidance on handling high-risk unpackaged food

The one clause that explains every state difference below

Standard 3.2.2A defines a food safety supervisor certificate as certification by either:

• (a) a registered training organisation, or
• (b) an organisation recognised by the relevant authority under the state's application Act.

Limb (b) is an open door, written into the national standard, for any state that wants to build its own certificate scheme on top of the national units. New South Wales is the only state that has walked through it. Victoria, Queensland and Western Australia rely on limb (a) alone, which is exactly why in those three the RTO's Statement of Attainment is the compliance artefact, and in NSW it is a separate state document.

So the NSW scheme is not a failure of harmonisation. It is the national standard being used as designed, by one state out of eight. That is the most useful single fact on this page for anyone operating across a border.

"Reasonably available" is a genuine compliance question, not a formality. A supervisor who is rostered off and unreachable is not reasonably available, and a single supervisor covering a seven-day operation needs a real answer to what happens on their days off. Queensland Health puts it concretely: the supervisor should physically work on site and oversee day-to-day handling, or be easily contactable where documented food handling procedures are in place; short absences such as holidays of up to 30 days are workable on that basis, but extended leave requires another supervisor to be appointed.

Tool three in detail: substantiation, for category one only

Category one businesses must make and keep records substantiating compliance with specific food safety management practices under Standard 3.2.2 for:

• Receipt of potentially hazardous food at correct temperatures — 5 °C or below, or 60 °C or above
• Storage of potentially hazardous food under temperature control
• Process steps that achieve microbiological safety, meaning pathogen reduction
• Minimising the time food spends at growth-permitting temperatures
• Cooling and reheating within the specified timeframes
• Display of potentially hazardous food under temperature control
• Transportation of potentially hazardous food under temperature control
• Cleaning and sanitising of food contact surfaces and equipment

Records must be kept for three months after being made, and must be accessible at the premises. A business may instead demonstrate compliance by other means — but if an authorised officer determines it cannot, the officer may require records to be kept. See how long do I need to keep records for.

Why the same standard produces four different regimes

Before the table, the mechanism, because it makes the table predictable rather than arbitrary.

FSANZ writes the standards under the Food Standards Australia New Zealand Act 1991 (Cth). They are then adopted by reference into each state and territory's food Act — the application Act. Standards 3.2.2 and 3.2.2A apply "in Australia only" and, on their own, have no legal force; they acquire force only through the application Act of the place you are standing in. The regulatory guidance states the boundary in one sentence:

Enforcement, penalties, business classification and any state-issued certificate are matters for the application Act, not for the Code.

Every difference in the table below is one of those four things. The Code decides what a business must have and deliberately leaves how to the states.

Six consequences follow.

Queensland is broader than the standard. The trigger is holding a food business licence, not the category. A licensable food business is one involving the manufacture of food; the retail sale of unpackaged food by an entity other than a non-profit; or the sale, on at least 12 days each financial year, of meals prepared by a non-profit at a particular place. Section 86 then requires the supervisor to be in place within 30 days after the licence is issued, and the licensee to at all times continue to have one, with a maximum penalty of 50 penalty units. So a licensed business that would not be category one or two under Standard 3.2.2A still needs an FSS in Queensland.

New South Wales issues its own document. Everywhere else the nationally recognised Statement of Attainment is the compliance artefact. In NSW it is a prerequisite to a separate, state-issued FSS certificate defined by s 106B(3). RTOs must be approved by the NSW Food Authority under s 106H, each approved RTO carries a Food Authority approval number separate from its national RTO code on a list revised at least annually, the certificate carries four mandatory key focus areas — allergen management, cleaning and sanitising practices, safe egg handling, and Food Act offences — and it must be issued within 10 working days of successful completion. The Authority also caps what an approved RTO may charge to issue it, separately from the training fee; confirm the current cap with the Authority rather than relying on a figure printed anywhere.

The classic NSW error is keeping the wrong piece of paper. An NSW-approved RTO issues two separate documents: the Statement of Attainment and the NSW FSS certificate. A business that keeps only the Statement of Attainment on premises has not satisfied s 106G. NSW also attaches 50 penalty units for an individual and 100 for a corporation to the appointment duty itself, with one narrow defence allowing food to be processed and sold by retail on not more than 30 days while a replacement is appointed.

Queensland will not accept RPL for recertification. Recognition of prior learning is fine for initial competency, but for the mandatory five-yearly recertification of a category one or two supervisor, Queensland Health states flatly that it will not be accepted — the complete course must be repeated, or a refresher course taken where an RTO offers one. Victoria does the exact opposite and actively encourages RPL. Western Australia does not state a position, and expressly accepts online delivery — its provider table carries a dedicated online-course column.

Victoria's sanction is not a fine, and that is the one row people misread as leniency. Nothing attaches to s 19GA of the Food Act 1984. The consequence of having no supervisor is refusal of registration or renewal, or revocation or suspension of the registration of the premises. A fine is a cost; a suspended registration is a closed business.

Western Australia's published provider list is not an approval scheme. This is the same trap as "OLGR-approved" in liquor. WA Health publishes a table of RTOs offering food safety supervision training, including interstate providers, but it is a convenience listing of self-notified providers. WA requires national registration, not WA approval. A provider absent from the table is not disqualified, and a provider claiming to be "WA-approved" is describing a scheme that does not exist. NSW is the opposite case: there the register genuinely is an approval scheme, under s 106H. WA also publishes accepted equivalents including SIRRFSA001, HLTSS00061 and the superseded SITSS00051 (SITXFSA001 + SITXFSA002).

In Victoria, your premises class decides it

Victorian councils classify every food premises on the highest-risk activity undertaken there, under the Food Act 1984. The class determines registration, records and whether an FSS is needed at all.

Five provisions do the work, and it is worth having them by number because councils cite them:

The third limb of s 19G is the one businesses fail without noticing. Authority is a real requirement: nominating a junior casual because they were free to attend the course does not satisfy s 19G, however current their certificate.

Safe Food Victoria states the rule as Class 1, most Class 2 and Class 3A premises must have a supervisor. Class 4 is the only class that notifies rather than registers. A Class 2 community group is exempt from the FSS duty only if all three conditions hold: the proprietor is a community group, it operates for no more than two consecutive days at a time, and most people handling the food are volunteers. Premises running a QA food safety program that includes competency-based or accredited staff training are also exempt, under s 19GA(2). Safe Food Victoria directs businesses to the FoodSmart tool to build a compliant program.

One honest note on the five years in Victoria. Safe Food Victoria publishes no Victorian renewal or refresher period at all. Its food safety supervisor page, last updated 29 June 2026, says prior training "does not usually" need repeating and confirms superseded course codes remain valid. The five-year requirement reaches Victoria through clause 3.2.2A—2, applied by the Food Act 1984, rather than through a Victorian instrument. It applies — but if your council cannot show you a Victorian page saying "five years", that is not evidence against it, and the source to cite is the Code.

Which units satisfy the requirement

The unit set depends on the state and the sector.

The single most common and most expensive mistake. SITXFSA005 alone is a food handler unit. It satisfies the food handler training requirement in all four states. It does not make anyone a Food Safety Supervisor in any of them. The FSS role needs SITXFSA006 as well — the difference between SITSS00068 and SITSS00069 is exactly that one unit. A business that has sent staff on a one-day food handling course and believes it now has an FSS does not have one.

The health and community services set is a second trap, and it needs stating precisely because it is usually stated wrongly:

• Standard 3.2.2A names no sector units at all. The health and community services requirement is a state determination, published by Safe Food Victoria and by Queensland Health. In Victoria those settings are Class 1 premises, so the requirement is real rather than theoretical.
• New South Wales names no sector-specific units in its published supervisor requirements. A page telling you the HLTFSE units are mandatory in NSW is telling you something NSW has not published.
• Western Australia treats them as an equivalent, publishing HLTSS00061 — the same three units bundled as a skill set — rather than confining health or childcare businesses to it.
• Safe Food Victoria accepts SIRRFSA001 and the hospitality pair as alternatives to each other for both hospitality and retail, so someone holding SITXFSA005 and SITXFSA006 is covered in a Victorian deli as well as a restaurant. It also confirms there is no Victorian requirement to train beyond the minimum competencies listed.

What the two hospitality units actually assess

Neither unit is a quiz, and the performance evidence is specific.

SITXFSA005 Use hygienic practices for food safety requires hygienic food handling in line with organisational procedures, demonstrating each of the following on at least three occasions: correct hand-washing procedures; appropriate use of uniform and personal protective equipment; effective personal health and hygiene practices; and hygienic food service. It also requires the procedures for reporting unsafe hygiene practices.

SITXFSA006 Participate in safe food handling practices goes further. It requires correct methods of controlling food hazards at each of nine critical control points — receiving, storing, preparing, processing, displaying, serving, packaging, transporting and disposing — plus the procedure to calibrate a temperature probe so readings are accurate, and the procedure for reporting food contamination incidents.

The difference is the point. SITXFSA005 is about the individual's own conduct. SITXFSA006 is about the whole system, using a HACCP-style approach to hazards, which is why it is the supervisor's unit. The probe calibration requirement is the practically important one: every temperature record on a premises depends on the probe being accurate, and an uncalibrated probe produces records that are worse than none.

A compliance checklist

1. Work out your category from what you do, not what you are called. If you cook, assume category one.
2. If you are neither, check clause 3 of Standard 3.2.2 anyway — it has applied since 2000 and sets no course or refresher, only competence.
3. If you are category one, set up the records for the eight practice areas and keep them three months, on premises.
4. Identify your FSS and check the issue date on the certificate, not just that one exists.
5. In Victoria, check the person as well as the certificate — s 19G requires ability and authority.
6. In NSW, confirm you hold the state certificate as well as the Statement of Attainment, from an approved RTO, and check its Food Authority approval number as well as its RTO code.
7. Check whether your state or sector names specific units — WA names SITSS00069, and Victoria and QLD publish the HLT set for health and community services.
8. Confirm every food handler completed training before starting the prescribed activity.
9. In Victoria, confirm your premises class with your council, since that is what triggers the duty.
10. Diarise the five-year FSS recertification, and check whether your state accepts RPL for it.

What we can and cannot give you

We hold SITSS00069 Food Safety Supervision and SITSS00068 Food Handling on our scope of registration, both since 10 June 2022 at the extent deliver and assess, and deliver the underlying units.

In Victoria, Queensland and Western Australia, the nationally recognised Statement of Attainment we issue is the compliance artefact for the hospitality pathway — and in Victoria for the retail sector as well, because Safe Food Victoria accepts the hospitality pair and SIRRFSA001 as alternatives to each other.

In New South Wales it is not sufficient on its own. We provide the correct national units and a valid Statement of Attainment, but we are not on the NSW Food Authority's approved provider list — that list was read in full on 1 September 2026. We therefore cannot issue the NSW FSS certificate a business must keep on its premises under s 106G, and the NSW mandatory key focus areas are not certified through us. A NSW business relying only on our Statement of Attainment does not hold what NSW law requires.

In health and community services it is not the right product either. Of the three units Victoria and Queensland publish for that sector, only HLTFSE001 is on our scope. HLTFSE005, HLTFSE007 and FBPFSY2002 are not. A hospital, aged care or childcare kitchen needs a provider that holds all three, and that is checkable on training.gov.au for any provider, including this one.

Both limits are stated plainly because getting either wrong carries consequences, and because no provider's marketing is a substitute for the regulator's own list.

About us

We are Complete Hospitality Training, RTO 3722, CRICOS 04242E. Level 3, 28 Elizabeth Street, Melbourne VIC 3000, and 410 Elizabeth Street, Surry Hills NSW 2010. Contact melbourne@cht.edu.au or +61 3 9654 1554.

See also Food Safety Supervisor, food handling, virtual food handling, how long do I need to keep records for, all courses and the student toolkit.

We link to the relevant course and regulatory sources in this guide. Check those sources for current requirements, and confirm course availability, delivery, fees and entry requirements with us before enrolling.

Source records and further guidance

We link the unit records and regulator guidance relevant to this page below. Check the current source before making an enrolment, licensing or employment decision.

• SITXFSA005 Use hygienic practices for food safety
• SITXFSA006 Participate in safe food handling practices
• SITSS00069 Food Safety Supervision Skill Set
• HLTFSE001 Follow basic food safety practices
• SITSS00068 Food Handling Skill Set
• Food Safety Supervisor certificate requirements (New South Wales)
• Food Standards Code — Standards 3.2.2 and 3.2.2A (food safety practices and food safety management tools)